VCOM Institutional Policy and Procedure Manual

VCOM Federal Funds Procurement Policy

Policy #U005

Edward Via College of Osteopathic Medicine

Policy Order No.: U005 Effective Date:

December 17, 2010

Revised:

August 2011; December 2011; August 20, 2014

______________________________________ Dixie Tooke-Rawlins, DO President Signature on File

__________________________________________________________________________________________________________________________ VCOM Federal Funds Procurement Policy __________________________________________________________________________________________ 1. G ENERAL POLICY ......................................................................................................................................... 1 2. C ODE OF ETHICS ........................................................................................................................................... 1 3. A CQUISITION PROCEDURES .......................................................................................................................... 2 4. ADDITIONAL POLICIES WHEN USING FEDERAL FUNDS TO PURCHASE ........................................................... 3 5. D URATION OF P OLICY .................................................................................................................................. 3 1. G ENERAL POLICY The Federal Procurement Policy is to ensure the policies and procedures shall be followed when VCOM purchases equipment, materials, supplies, property, or services from an outside source utilizing federal funds. All directors, employees, or agents who participate in the selection or acceptance of a contract for equipment, materials, supplies, or services must comply with VCOM’s conflict of interest policy. No director, employee, or agent shall participate in the selection or acceptance of a contract involving a conflict of interest without the approval of the board. “Conflict of interest” includes situations in which the employee, family member, or board member has a financial interest in the business or individual selected for the contract. No director, employee, or agent who participates in the selection or acceptance of a contract for equipment, materials, supplies, or services shall use such items for personal use. No director, employee, or agent shall solicit or accept gratuities, favors, or anything of value from contractors, potential contractors, or parties to agreements with VCOM. Purchases funded by federal grant funds must adhere to regulations found in 2.CFR.215 (Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Learning, Hospitals, and Other Non-Profit Organizations). Sections 215.41 – 215.48 identify required procurement standards. Procurements made with federal funds are reviewed for compliance with the Federal Acquisition Regulation and Code of Federal Regulations. The Office of Research Administration is required to retain backup documentation such as quotes, bids and cost analyses on file for federal auditors. C ODE OF ETHICS The nature of purchasing functions makes it critical that all players in the process remain independent, free of obligation or suspicion, and completely fair and impartial. Maintaining the integrity and credibility of a purchasing program requires a clear set of guidelines, rules and responsibilities to govern the behavior of purchasing 2.

VCOM Federal Funds Procurement Policy

Page 1 of 3